ML18149A168
| ML18149A168 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/08/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 86-238, NUDOCS 8606020208 | |
| Download: ML18149A168 (4) | |
Text
l VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 o10'r;.,..
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W. L. STEWART VICE PRESIDENT NucLEAR OPERATIONS May 8, 1986 Dr. J. Nelson Grace Regional Administrator Region II U. S. Nuclear Regulatory Commission Suite 2900 101 Marietta St., N.W.
Atlanta, Georgia 30323
Dear Dr. Grace:
VIRGINIA ELECTRIC AND POWER COMPANY
'SURRY POWER STATION UNIT NOS. 1 AND 2 Serial No.
NO/JBC:
Docket Nos.
License Nos.
NRC INSPECTION REPORT NOS. 50-280/86-05 AND 50-281/86-05 86-238 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of April 8, 1986, in reference to the inspection conducted at Surry Power Station on February 24 - 28, 1986, and reported in Inspection Report Nos. 50-280/86-05 and 50-281/86-05.
Our response to the Notice of Violation is addressed in the attachment.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact us.
Very truly yours, l<J~J~
f-W. L. Stewart Attachment
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cc:
Mr. Lester S. Rubenstein, Director PWR Project Directorate No. 2 Division of PWR Licensing-A NRC Senior Resident Inspector Surry Power Station Mr. Chandu P. Patel NRC Surry Project Manager PWR Project Directorate No. 2 Division of PWR Licensing-A
,/
RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRG INSPECTION CONDUCTED ON FEBRUARY 24 - 28, 1986 INSPECTION REPORT NOS. 50-280/86-05 AND 50-281/86-05 NRG COMMENT:
The following violation was identified during an inspection conducted on February 24 - 28, 1986.
The Severity Level was assigned in accordance with the NRG Enforcement Policy (10 CFR Part 2, Appendix C).
Technical Specifications 6.4.A.2 and 6.4.D require detailed written procedures with appropriate check off lists and instructions to be followed for testing instruments, components and systems involving the nuclear safety of the station.
Administrative Procedure (ADM)-
89, Test Control, establishes the surveillance schedule and test program to ensure safety-related instruments, components and systems perform satisfactorily and are operable.
It also requires test results to be properly documented and evaluated to verify all test requirements are satisfied.
Contrary to the above, ADM-89 was not followed in that:
- a.
Testing prescribed by 1-PT-16.6 was not performed within the Technical Specification required schedule.
The test was due 11/9/85 and could have been done as late as 12/26/85, but was not performed until 1/29/86.
- b.
Test results were not properly documented and evaluated in the last steps in tests, 1-PT-16.5, 1-PT-16.6, and 2-PT-16.6 which were performed between January 28 and February 5, 1986.
This is a Severity Level IV violation (Supplement I).
RESPONSE
- 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
- 2.
The violation is correct as stated.
We note however, that the test, when performed on January 29,
- 1986, verified the containment equipment hatch leakage had remained within allowable limits since the previous test.
REASONS FOR THE VIOLATION:
1-PT-16.6 was not performed within the Technical Specification required schedule, that is, no later than December 26, 1985, as a result of a
misunderstanding of the testing requirements by
Operations personnel responsible for performing the test. This test, a leak test of the containment equipment hatch, was being manually tracked due to performing the test on an increased frequency schedule to coincide with snubber outages.
At the time of the inspection, the snubber outage frequency had changed and no longer coincided with the 1-PT-16.6 test interval.
Test 1-PT-16.6 had not yet been included in the station computerized Periodic Test tracking system.
This resulted in misinterpretation of the testing requirement.
Local leak rate test procedures 1-PT-16.5, 1-PT-16.6, and 2-PT-16.6 had required the Surveillance and Test Engineering Group to transfer the local test results to the master leakage test (PT-16.1) following evaluation but prior to transmittal of the completed local test procedures to the records vault.
In the cases identified by the inspector, ari administrative oversight in the Surveillance and Test group allowed the procedures to be forwarded to the vault without the required transfer of data to the master procedure and without the signoffs on the local test procedure, indicating that the information had been transfered and the tests were complete.
- 3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The computerized Periodic Test tracking system has been expanded to include those tests which have fixed frequency test intervals.
Reports are provided to station management concerning tests which have reached their scheduled test date. Those few tests without fixed intervals which are not included in the computerized system have been included under an engineering procedure to ensure that they are manually tracked.
For the local leak rate tests, test results were compiled to verify that total leakage remains within allowable limits.
In addition, a method of independent second review of completed tests has been instituted within the Surveillance and Test group, to assure that tests have been properly completed in accordance with station procedures.
- 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
The actions described above are sufficient to assure full compliance.
However, in the case of the local leak test program, a more efficient program of tracking test results has been developed, and is being implemented.
Local leak rate test results will be evaluated by the Surveillance and Test group using an engineering procedure.
These procedural enhancements are presently in progress.
- 5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.